CMMC CHANGED THE FSO ROLE.
Understand where industrial security ends, cybersecurity begins, and how FSOs fit into CMMC readiness.
Executive Brief
Defense Counterintelligence and Security Agency (DCSA) inspections are not routine administrative events. They are structured evaluations of how well your organization is complying with the National Industrial Security Program Operating Manual (NISPOM), codified at Title 32 of the Code of Federal Regulations (CFR) Part 117.
In 2026, inspections will continue to reflect a risk-based approach. Facilities handling classified contracts, operating under a Facility Clearance (FCL), or managing complex subcontractor relationships should expect deeper scrutiny.
DCSA reviews more than policy binders. They examine execution. Investigators look for alignment between written procedures, system configurations, personnel training, and real-world practice.
Dig deeper below to learn what DCSA Industrial Security Representatives review, what contractors commonly overlook, and how to prepare with confidence.
What DCSA Reviews During an Inspection
Facility Clearance and Organizational Structure
DCSA will validate that your FCL remains current and properly sponsored. They will examine:
- Key Management Personnel listings and exclusion resolutions
- Ownership, Control, or Influence documentation if applicable
- Board resolutions and corporate governance alignment
- Organizational charts reflecting cleared and uncleared roles
If your leadership team has changed and records were not updated in the National Industrial Security System, expect questions.
Not sure how you’d perform under DCSA review? Take our Industrial Security Check quiz to uncover hidden gaps, assess your risk level, and determine whether you need immediate Facility Security Officer (FSO) support.
NISPOM Implementation
Title 32 CFR Part 117 requires contractors to implement structured security programs. Inspectors will evaluate:
- Your written (SPP) Standard Practice Procedures
- Appointment letters for the FSO and Insider Threat Program Senior Official
- Classified safeguarding procedures
- Marking, storage, transmission, and destruction processes
The focus is consistency. If your procedure says classified material is stored in a General Services Administration-approved container, investigators will verify that the container exists, is properly maintained, and access is controlled.
Insider Threat Program Maturity
The Insider Threat Program is frequently reviewed in depth. DCSA expects more than a policy statement. In 2026, investigators evaluate whether your program functions as an operational risk management process rather than a compliance formality.
They will assess:
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Insider Threat training completion records and evidence of recurring engagement
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Documentation of Insider Threat working group meetings and cross-functional participation
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Audit log review processes, including frequency, reviewer identity, and documented outcomes
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Integration between human resources, information technology, and security functions
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Clear escalation procedures for identified risk indicators
ISRs may ask how anomalous behavior is identified, who performs analysis, and what triggers further review or reporting. If leadership or the Insider Threat Program Senior Official cannot articulate these processes, it signals weak program ownership.
A common gap is failing to document analysis. If you collect audit data but cannot demonstrate review and escalation procedures, the program appears performative rather than operational.
Self-Inspection and Corrective Action
Self-inspections are mandatory under NISPOM. DCSA evaluates whether you:
- Conduct annual self-inspections
- Identify findings with specificity
- Track remediation through documented corrective actions
- Close findings with evidence
A checklist without documented follow-up signals weak internal oversight.
Classified Contract Administration
Investigators review contract classification specifications, subcontractor flow-downs, and visit authorizations.
They may request:
- DD Form 254 alignment with safeguarding procedures
- Visit authorization letters
- Subcontractor clearance verification
Breakdowns often occur when classified requirements evolve but internal documentation does not.
What Contractors Commonly Miss
Documentation Drift
Policies referencing outdated regulations or legacy processes undermine credibility. If your documentation still cites superseded guidance instead of current 32 CFR Part 117 language, it signals neglect.
Insider Threat Over-Reliance on Templates
Templates are useful starting points, but DCSA expects facility-specific implementation. Generic language with no evidence of customization is a red flag.
Weak Audit Trails
It is not enough to state that logs are reviewed. You must show:
- Dates of review
- Reviewer identity
- Noted anomalies
- Escalation outcomes
Without this, there is no defensible oversight trail.
Disconnected Cyber and Industrial Security Programs
Although DCSA inspections focus on classified safeguarding, cybersecurity expectations increasingly intersect with industrial security responsibilities. Misalignment between your System Security Plan and physical security processes can create avoidable scrutiny.
Untrained Key Personnel
Security responsibilities extend beyond the Facility Security Officer. Program managers, cleared employees, and senior leadership must understand their roles. Training records should reflect recurring engagement, not one-time onboarding.
Your 2026 DCSA Inspection Prep Checklist
Use this structured review six to nine months before a scheduled inspection.
Governance and Structure
- Confirm Key Management Personnel listings are current
- Validate FCL status and sponsorship
- Update organizational charts
Policy Alignment
- Review Standard Practice Procedures against 32 CFR Part 117
- Ensure classified safeguarding procedures reflect actual practice
- Update Insider Threat Program documentation
Training and Awareness
- Verify annual refresher training completion
- Confirm Insider Threat training is documented
- Brief senior leadership on inspection expectations
Operational Controls
- Inspect storage containers and access logs
- Validate destruction records
- Review visitor control procedures
Self-Inspection and Remediation
- Conduct a documented mock inspection
- Identify gaps with evidence-based findings
- Assign corrective actions with deadlines and ownership
If you are newly appointed or expanding your responsibilities, our FSO’s Guide to CMMC walks through how industrial security and cybersecurity responsibilities intersect under 32 CFR Part 117 and CMMC Level 2.
Why Early Preparation Matters
DCSA inspections influence your facility’s risk profile and future oversight level. Strong performance builds trust and may reduce intrusive follow-up. Weak performance increases monitoring and administrative burden.
More importantly, inspections reflect your organization’s role in protecting national security information. Compliance is not abstract. It is operational discipline.
Preparing early allows time to correct structural weaknesses rather than rushing documentation weeks before investigators arrive.
If you are unsure how your facility would perform under review, now is the time to test it.
FAQs
How often does DCSA conduct inspections?
Inspection frequency depends on your facility’s risk profile, classified involvement, and prior inspection results. High-risk facilities may see more frequent reviews, while lower-risk organizations may have longer intervals, but all cleared contractors should maintain continuous readiness.
What is the most common finding during inspections?
Common findings include insufficient documentation of Insider Threat activities, outdated policies, and incomplete self-inspection corrective action tracking. These issues often stem from weak follow-through rather than misunderstanding requirements.
Can a mock inspection really make a difference?
Yes. A structured mock inspection surfaces gaps in documentation, training records, and operational consistency before DCSA identifies them. It also helps leadership understand expectations and reduces last-minute scrambling.
